Taxpayers across the country rely on advice from their accountants and CPAs to meet the complicated requirements of the U.S. Tax Code. But a new case, Jarnagin v United States, in the U.S. Court of Federal Claims suggests that CPA

The IRS Large Business and International (LB&I) division last week publicly released a “practice unit” that addresses what the term “substantially complete” means with reference to international information return penalties, particularly Form 5471. The IRS recently released a new International Practice

Last year, the US Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant

Many of our clients with foreign accounts have received FATCA letters. The letters seek personal information regarding the account holder in order to comply with the US FATCA law. In recent weeks, government authorities in a few foreign countries have

The reporting requirements for IRS Form 5471 are complex, including ‘category of filer’ and required schedules. However, very few taxpayers know that there are special simplified filing rules for a foreign dormant corporation. IRS Revenue Procedure 92-70, specifies specific,

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers now have until October 16 to submit their FBARs for

On March 7th, the New Jersey Department of Revenue released its “Manual of Audit Procedures” to the public, which is intended to provide a comprehensive overview of the procedures and guidelines available to it for completing all types of audits,

The US Dept of Justice (DOJ) Tax Division recently published it annual summary highlights of civil tax matters. The publication is linked here (Updated through December 16, 2016), and contains brief summaries DOJ Tax activity (decisions, court filings, etc.). Last year it

Earlier this month, the IRS’ Large Business and International division released its list of 13 focus areas for issue- based examinations and concerns for compliance. One of those areas involves the IRS Offshore Voluntary Disclosure Program. Entitled, “OVDP Declines-Withdrawals

The government has made a few recent form updates regarding the filing requirements for the following forms:  FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) – automatic extension granted  Form 8938 (Statement of Specified Foreign Financial